Justia Criminal Law Opinion SummariesArticles Posted in Connecticut Supreme Court
Bowens v. Commissioner of Correction
The Supreme Court affirmed the judgment of the habeas court denying Petitioner's second petition for a writ of habeas corpus challenging his 1998 murder conviction, holding that the habeas court properly denied the petition. Specifically, the Court held (1) the habeas court correctly concluded that Petitioner failed to establish that he was actually innocent of the murder; (2) the habeas court properly determined that the identification procedures employed in this criminal case did not violate Petitioner's due process rights; (3) the habeas court correctly concluded Petitioner's first habeas counsel did not provide ineffective assistance of counsel; and (4) assuming, for the sake of argument, that the habeas court should have resolved Petitioner's cruel and unusual claims on the merits, Petitioner could not prevail on those claims, and therefore, it need to be determined whether the habeas court improperly applied the doctrine of res judicata. View "Bowens v. Commissioner of Correction" on Justia Law
Griffin v. Commissioner of Correction
The Supreme Court affirmed the judgment of the habeas court rendering judgment against Petitioner, a juvenile offender, on his claim that the evolution of Connecticut's "standards of decency" regarding acceptable punishments for children who engage in criminal conduct has rendered the transfer of his case to the regular criminal docket and resultant sentencing unconstitutional, holding that Petitioner was not entitled to relief on his claims. Petitioner, who was fourteen years old when he committed felony murder, argued that his sentence as an adult after his case was automatically transferred to the regular criminal docket violated the state prohibition against cruel and unusual punishment. The habeas court denied relief. The Supreme Court affirmed, holding (1) transferring the case of a fourteen year old defendant to the regular criminal docket comports with evolving standards of decency and, therefore, does not violate the Connecticut constitution; and (2) Petitioner's forty year sentence does not violate the constitutional prohibition against cruel and unusual punishment after the provisions of P.A. 15-84 made Petitioner eligible for parole after serving sixty percent of his original sentence. View "Griffin v. Commissioner of Correction" on Justia Law
State v. Williams-Bey
The Supreme Court affirmed the decision of the Appellate Court affirming the trial court's dismissal of Defendant's motion to correct an illegal sentence, holding that because Defendant is now eligible for parole under No. 15-84 of the 2015 Public Acts (P.A. 15-84) the Connecticut constitution did not require a resentencing of his unconstitutional sentence. Defendant, a juvenile offender, was convicted of murder and sentenced to thirty-five years' imprisonment. At the time of sentence, Defendant was indelible for parole. Thereafter, decisions by the United States and Connecticut Supreme Courts and enactments by the legislature resulted in changes to the sentencing scheme for juvenile offenders. To comply with federal constitutional requirements the legislature passed P.A. 15-84. As a result, Defendant will be parole eligible after serving twenty-one years. Thereafter, Defendant filed a motion to correct an illegal sentence, asserting a violation of Miller v. Alabama, 467 U.S. 460 (2012). The trial court dismissed the motion for lack of jurisdiction. The Appellate Court ultimately affirmed on the ground decided in State v. Delgado, 151 A.3d 345 (Conn. 2016). The Supreme Court affirmed, holding that, consistent with Delgado and the federal constitution, Defendant's parole eligibility afforded by P.A. 15-84, 1 was an adequate remedy for the Miller violation. View "State v. Williams-Bey" on Justia Law
State v. McCleese
The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the legislature may and has remedied the constitutional violation in this case with parole eligibility. Defendant, a juvenile offender, was convicted of murder and other offenses. Defendant was originally sentenced to imprisonment for the functional equivalent of his lifetime without the possibility of parole. Subsequently, decisions by the United States and Connecticut Supreme Courts and enactments by the legislature resulted in changes to the sentencing scheme for juvenile offenders. As a result, Defendant will be parole eligible when he is about fifty years old. Defendant filed a motion to correct an illegal sentence based on Miller v. Alabama, 467 U.S. 460 (2012). The trial court ultimately dismissed the motion, concluding that Defendant's claim was moot in light of the United States Supreme Court's holding that Miller applied retroactively. The Supreme Court affirmed, holding (1) parole eligibility afforded by No. 15-84 of the 2015 Public Acts (P.A. 15-84) is an adequate remedy for a Miller violation under the Connecticut constitution; and (2) P.A. 15-84, 1 does not violate the separation of powers doctrine or Defendant's right to equal protection under the federal constitution. View "State v. McCleese" on Justia Law
State v. Ayala
The Supreme Court affirmed Defendant's conviction of murder and conspiracy to commit murder, holding that there was no error in the trial court's evidentiary rulings. On appeal, Defendant argued that the trial court erred in admitting testimony implicating him in the murder under the coconspirator exception to the hearsay rule and improperly admitted certain state of mind evidence. The Supreme Court disagreed, holding (1) even if the trial court incorrectly admitted the evidence under the coconspirator hearsay exception, the jury's verdict wasn't substantially affected by any such error; and (2) the trial court did not abuse its discretion in determining that the victim's state of mind was relevant as evidence of the deteriorating nature of his relationship with Defendant's gang from which the jury could reasonably infer Defendant's motive to kill him. View "State v. Ayala" on Justia Law
State v. Elmer G.
The Supreme Court affirmed the judgment of the appellate court upholding Defendant's convictions for several offenses stemming from the sexual assault of his minor daughter, holding that the evidence was sufficient to support Defendant's conviction for three counts of criminal violation of a restraining order and that the prosecutor did not commit misconduct. Specifically, the Court held (1) there was sufficient evidence from which the jury could conclude that Defendant had "knowledge of the terms of the order" because the court expressly instructed Defendant to limit contact with the children and Defendant heard Spanish language translations of the terms of the order; and (2) the prosecutor's comments and questions were not improper. View "State v. Elmer G." on Justia Law
State v. Robert H.
The Supreme Court reversed the judgment of the Appellate Court concluding that Appellant's claim that his conviction violated the corpus delicti rule was unreviewable on appeal, holding that unpreserved corpus delicti claims are reviewable on appeal. Defendant was convicted of two counts of risk of injury to a child arising from two alleged incidents of sexual misconduct. Defendant appealed, arguing that the only evidence that he committed the second alleged act of misconduct were statements he made to the police and, therefore, that his second conviction violated the corpus delicti rule. Defendant, however, did not raise the corpus delicti issue or challenge the admissibility of his statements at trial. The Appellate Court dismissed the appeal, concluding that corpus delicti is an evidentiary rule that must be raised at trial to be reviewable on appeal. The Supreme Court reversed for the reasons set forth in a companion case decided today, State v. Leniart, __ A.3d __ (2019), holding that Defendant's corpus delicti claim was reviewable on appeal. View "State v. Robert H." on Justia Law
State v. Leniart
The Supreme Court affirmed in part and reversed in part the judgment of the Appellate Court reversing Defendant's conviction for murder and three counts of capital felony and remanding the case for a new trial, holding that the Appellate Court erred in concluding that a videotape and expert testimony were improperly excluded during trial. Specifically, the Court held (1) Defendant's corpus delicti claim was reviewable on appeal because it was not merely evidentiary, but the Appellate Court properly concluded that there was sufficient evidence to support the conviction; (2) the Appellate Court erred in concluding that the trial court's erroneous exclusion of the videotape was not harmless; and (3) the Appellate Court erred in concluding that the trial court abused its discretion in precluding the expert testimony proffered by Defendant. View "State v. Leniart" on Justia Law
State v. Tony M.
The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and risk of injury to a child, holding that none of Defendant's claims of error warranted reversal of his convictions. Defendant was convicted of killing his seven-month-old son in an incident in which Defendant also attempted suicide. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress certain evidence arising from statements that Defendant had made to the police while in the hospital; (2) even assuming that the trial court improperly admitted Defendant's statements made at the hospital in violation of Conn. Gen. Stat. 54-lo because the interview was not recorded, any such error was harmless; and (3) the trial court did not err by precluding Defendant from introducing into evidence Defendant's offer to plead guilty to manslaughter in exchange for twenty-five years' incarceration. View "State v. Tony M." on Justia Law
State v. Walker
The Supreme Court reversed in part the judgment of the Appellate Court concluding that Defendant failed to establish that his Sixth Amendment right to confront witnesses against him was violated at trial, holding that, under the specific circumstances of this case, Defendant established a violation of his right to confrontation. Defendant was found guilty of felony murder, manslaughter in the first degree with a firearm, and other offenses. At trial, the State introduced evidence that Defendant's DNA profile, which had been generated from a post arrest buccal swab, matched the DNA found on evidence from the crime scene. The State, however, did not call as a witness the analyst who processed the buccal swab and generated the DNA profile used in the comparison. On appeal, the Appellate Court concluded that Defendant's Sixth Amendment claim failed because the admission of DNA evidence did not violate Defendant's constitutional right to confrontation. The Supreme Court reversed, holding that the generation of DNA's profile was testimonial and that Defendant's Sixth Amendment right to confront witnesses against him was violated. View "State v. Walker" on Justia Law